It sounds like it's a step in the right direction.
I know that budget 2025 also includes intentions to modernize Canada's transfer pricing rules to better align with international consensus on the application of the arm's-length principle, as reflected in the OECD transfer pricing guidelines. One aspect of that is to introduce new rules that provide more detail on how cross-border transactions between non-arm's-length persons must be analyzed, including a new transfer pricing adjustment application rule and a new definition of economically relevant characteristics.
Would you say those are also steps in the right direction? Would you care to comment?
